CoC & ESG Application Guide

The CoC Annual Competition

Unlike formula grants where funding flows automatically, the Continuum of Care program operates through an annual national competition. HUD publishes a Notice of Funding Opportunity (NOFO) each year, typically in the summer or early fall, that establishes the competition rules, scoring criteria, funding priorities, and deadlines for that cycle. The competition involves two layers: a local competition within each CoC, followed by a national scoring and award process by HUD.

The total amount available nationally is determined by the annual congressional appropriation, which has been approximately $3 billion in recent years. Each CoC has an Annual Renewal Demand (ARD) — the total amount needed to renew all existing CoC grants — and a bonus/reallocation amount that can fund new projects. Understanding these funding tiers is essential for strategic planning.

The Local Competition Process

Before any project application reaches HUD, it must pass through the CoC's local competition. The collaborative applicant manages this process, which typically follows this timeline after the NOFO is released:

The Collaborative Application Structure

The CoC submission to HUD consists of several interconnected components. Each component is scored separately, and the total score determines the CoC's overall competitiveness:

CoC Registration

Annual registration that establishes the CoC's geographic boundaries, identifies the collaborative applicant and HMIS lead, and confirms the CoC meets basic organizational requirements. Registration must be completed before the CoC Application can be submitted.

CoC Consolidated Application

The narrative application submitted by the collaborative applicant that describes the CoC's homeless response system, performance data, system coordination, strategic planning, and governance. This is where the CoC demonstrates its capacity and effectiveness. Key sections include:

• System performance: How the CoC performs on HUD's System Performance Measures (length of time homeless, returns to homelessness, placements to permanent housing, income growth, first-time homelessness)
• Coordinated entry: Description of the CoC's coordinated entry system, including coverage, assessment tool, prioritization, and referral processes
• HMIS: HMIS coverage rates, data quality, bed coverage, and use of HMIS data for system planning and performance management
• Project ranking and reallocation: How the CoC ranks projects, whether low-performing projects were reallocated, and the CoC's approach to performance-based funding decisions

CoC Priority Listing

The ranked list of all project applications (renewal and new) that the CoC is submitting to HUD. Projects are placed in two tiers:

• Tier 1: Projects within the CoC's Annual Renewal Demand (ARD) plus any planning and UFA costs. These projects are highly likely to be funded if the CoC Application scores above the minimum threshold.
• Tier 2: Projects above the Tier 1 line, including bonus projects and any projects that exceed the ARD. Tier 2 projects are funded in order of national ranking and are less certain to receive awards.

The CoC's ranking decisions directly determine which projects are funded. Projects placed high in Tier 1 are virtually guaranteed funding. Projects placed in Tier 2 or at the bottom of Tier 1 face more uncertainty. This is why the local competition and ranking process is so consequential.

Project Applications: New vs. Renewal

Individual organizations submit project applications through e-snaps as part of the CoC's consolidated submission. There are two types:

Renewal Project Applications

Existing CoC grants must be renewed annually through the competition. Renewal applications describe the project's current operations, performance data (from the most recent APR), budget, and any changes from the previous year. Strong renewal applications demonstrate consistent performance on key metrics: occupancy/utilization rates, exits to permanent housing, length of stay, income growth, and returns to homelessness.

Low-performing renewal projects risk being ranked lower in the Priority Listing or, in some CoCs, being reallocated — meaning their funding is redirected to a new, higher-performing project. The Reporting guide covers the performance metrics that drive renewal scoring.

New Project Applications

New projects are funded through the CoC's bonus allocation, through reallocation of existing funds from low-performing projects, or through Domestic Violence (DV) bonus funding. New project applications must demonstrate:

• The project addresses a gap in the CoC's current system
• The applicant has capacity to operate the proposed component type
• Housing First principles will be followed
• The project will participate in coordinated entry and HMIS
• Match commitments are documented
• The proposed budget is reasonable and cost-effective

CoC Governance and the Ranking Process

HUD requires each CoC to have a governance structure that includes a board, established policies and procedures for the local competition, and transparent ranking criteria. The governance structure must include representation from homeless or formerly homeless individuals. Key governance requirements that affect the application process:

• Written policies: The CoC must have written policies for the local competition, including scoring criteria, ranking methodology, and conflict of interest protections
• Performance-based ranking: HUD expects CoCs to use objective performance data in ranking decisions. CoCs that rank projects based on relationships rather than performance are at risk during HUD review.
• Reallocation: HUD scores CoCs on whether they reallocate funding from low-performing projects to higher-performing new projects. CoCs that never reallocate may receive lower scores.
• Conflict of interest: Board members and review committee members must recuse themselves from scoring or ranking decisions that involve their own organizations.

The e-snaps System

e-snaps is HUD's electronic grants management system for the CoC program. All CoC Registration, Consolidated Application, and project application forms are submitted through e-snaps. Key considerations:

• Registration: Organizations must register in e-snaps before the application period. New registrants should allow at least 2 weeks for the approval process.
• Applicant profile: Your organization's profile in e-snaps must match your SAM.gov registration (legal name, address, UEI). Mismatches will delay processing.
• Submission process: Project applicants submit their applications to the collaborative applicant in e-snaps. The collaborative applicant then includes them in the CoC's consolidated submission to HUD. You cannot submit directly to HUD.
• Common errors: Incomplete budget forms, mismatched UEI numbers, missing match documentation, and failure to complete all required sections are the most common e-snaps errors that delay or jeopardize applications.

ESG Allocation and Subrecipient Selection

ESG operates differently from CoC because it is a formula grant. ESG funds flow from HUD to recipients (states and entitlement jurisdictions) based on the CDBG formula. Recipients then typically subgrant to service providers through their own competitive or formula-based processes.

ESG Recipient Responsibilities

ESG recipients (states and entitlement cities/counties) must:

• Consult with the CoC(s) in their jurisdiction when allocating ESG funds
• Develop and follow written standards for administering ESG assistance
• Ensure subrecipients participate in HMIS and coordinated entry
• Comply with ESG expenditure limits (no more than 60% on emergency shelter and street outreach combined)
• Submit the ESG CAPER (Consolidated Annual Performance and Evaluation Report) to HUD

Applying as an ESG Subrecipient

If you are a nonprofit homeless service provider seeking ESG funding, your application goes to the ESG recipient (your state or local government), not to HUD directly. Each recipient has its own application process, timeline, and evaluation criteria. To position your organization:

• Identify whether your jurisdiction is an entitlement community or falls under state ESG administration
• Contact the ESG recipient to learn their application timeline and requirements
• Demonstrate your capacity to meet ESG program standards (24 CFR 576)
• Document your 100% match commitment before applying

Coordinated Entry Integration

Coordinated entry is not optional for CoC and ESG recipients — participation is a regulatory requirement under 24 CFR 578.7(a)(8) for CoC and 24 CFR 576.400(d) for ESG. Your application must demonstrate that your project will accept referrals through the CoC's coordinated entry system rather than maintaining independent intake processes.

In the application, you should describe how your project connects to coordinated entry, including your referral acceptance rate, average time from referral to enrollment, and any project-specific eligibility criteria that may limit which coordinated entry referrals you can accept. Projects with restrictive eligibility criteria that limit coordinated entry referrals will score lower.

Match Documentation for Application

Match commitments must be documented in the project application. For CoC projects, this means demonstrating the 25% match for all costs except leasing. For ESG, the 100% match requirement must be documented by the recipient (or passed to subrecipients). Acceptable match documentation includes:

• Cash match: Commitment letters from other funding sources (government grants, foundation awards, organizational funds)
• In-kind match: Documented value of donated goods, services, volunteer time, or facilities, with a defensible valuation methodology
• Other federal sources: Some federal funds may be used as match for CoC grants if the other program's regulations allow it. Verify with both programs before committing.

Insufficient match documentation is one of the most common reasons CoC project applications are weakened in the local competition. The Budget guide provides detailed match calculation and documentation guidance.

Application Best Practices

• Start early: Do not wait for the NOFO to begin preparing. Update your e-snaps profile, compile performance data from your most recent APR, and confirm your SAM.gov registration is current months before the competition opens.
• Know your performance data: Renewal scoring is heavily weighted by APR performance. Know your occupancy rates, exit destinations, income growth, and returns to homelessness before the competition starts so you can address any weaknesses.
• Engage with your CoC: Participate in CoC governance and planning year-round, not just during competition season. Organizations that are active CoC members have better relationships and understanding of local priorities.
• Document Housing First compliance: Ensure your program policies, intake procedures, and termination criteria reflect Housing First principles. Review the Compliance guide for Housing First fidelity requirements.